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CESTAT allowed the appeal, set aside the impugned order and quashed the demand. The tribunal held that the appellant established receipt and nature of services via ST-3 returns, balance-sheet figures and Form 26AS, entitling it to exemption for services rendered to educational institutions and supplies to the E-Village under the relevant notification. The tribunal rejected the authority's reliance on technical defects in invoices, affirmed that the provider's liability is distinct from the recipient's (negating reverse-charge attribution to the appellant), and found no justification for invoking the extended period of limitation. Consequential demands of service tax, interest and penalty were found without merit and discharged.